Gates v. Board of Education of Chicago

Fred Gates (plaintiff) worked as a building engineer for the Board of Education of Chicago (the board) (defendant). Rafael Rivera became Gates’s supervisor in 2012. In June 2013, Rivera allegedly told Gates during a performance meeting that Gates would never be promoted because of his age (i.e., nearly 50) and because Gates was Black. A few months later, Rivera allegedly told a racially insensitive joke during a meeting with Gates and called Gates the N-word. In November 2013, Rivera allegedly yelled at Gates and threatened to write up Gates’s “Black ass” so that Gates would receive low work evaluations and get fired. In March 2014, Rivera allegedly called Gates the N-word again during a meeting. Between 2013 and 2014, Gates took leave from work several times, including a one-month sick leave to seek medical treatment for homicidal thoughts Gates was having toward Rivera and other school administrators. Gates alleged that the homicidal thoughts were brought on by Rivera’s discriminatory conduct. Gates sued the board in federal district court in Illinois, alleging a racially hostile work environment in violation of Title VII of the Civil Rights Act of 1964 (Title VII). The district court granted summary judgment for the board, reasoning that a hostile-work environment claim required a showing that the workplace was “hellish,” and Gates had not shown that Rivera’s comments were severe or pervasive enough to have created a hellish workplace. Gates appealed.